Why are HME providers putting off applying for accreditation? Observers place the blame in part on various myths and misconceptions. One such fallacy holds that small HME providers, by dint of their size, will be excluded from competitive bidding—ergo, no point in becoming accredited if you are a mom-and-pop shop. "That couldn't be further from the truth," says Maryanne Popovich, RN, MPH, executive director of home care accreditation services for the Joint Commission on Accreditation of Healthcare Organizations (JCAHO), Oakbrook Terrace, Ill. "The regulations even require that CMS show small providers have not been excluded."

Other wrongheaded notions about accreditation would seem to have the opposite effect on providers, putting pressure on them to hurry with their applications. For example, there is a rumor that asserting accreditation will allow a DMEPOS to competitively bid on any and all products. Not so, warns Sandra C. Canally, RN, president of Spring House, Pa-based The Compliance Team Inc (the only for-profit, privately owned accrediting body to be approved by CMS). "Providers will be accredited to bid on the specific products that they've checked off on their enrollment forms and that they have been surveyed for. So, for example, if I accredit you for oxygen, beds, walkers, and manual wheelchairs, but not power wheelchairs, you will be able to submit claims for all those products except power wheelchairs—and, if you try to submit a power wheelchair claim, you simply won't be paid."

Maryanne Popovich

Mary Ellen Conway

Sandra C. Canally

Then there is the belief that all HME providers in the initial 10 cities must be accredited this year. This, too, turns out to be erroneous. "Let's say you're a DMEPOS in Pittsburgh," Popovich proposes. "Just because you're a DMEPOS provider doesn't mean you will necessarily have to be accredited first, even if Pittsburgh turns out to be one of the first-named cities. That's because CMS also will be naming products, not just cities. So, let's speculate that Pittsburgh is a first-10 city and that CMS names power wheelchairs, oxygen, and diabetic supplies as the first group of products there. In that scenario, if you are a Pittsburgh provider who does not offer any of those three products, then you don't have to be accredited in 2007. Eventually, you will have to be, but that's not going to be an issue for you the moment the identities of the first 10 cities are revealed."

Echoing that last statement is Canally: "A lot of providers think it is only the companies participating in competitive bidding that need to be accredited. The fact of the matter is that every provider that bills Medicare is going to need to be accredited—even the specialty providers."

Canally promises that her organization will do all in its power to expedite processing of accreditation applications from providers in the first 10 announced MSAs: "I don't want to see any small business providers who are committed to quality lose their ability to bill Medicare due to a failure to meet the accreditation deadline—so we're going to really be working hard at fast-tracking them through the process."

NATION OF PROCRASTINATION

Many HME providers in the handful of US cities where Medicare's new accreditation rules soon will take effect have yet to even invite inspection by CMS-approved quality standards certifiers. With accreditation in those pilot locales slated to commence this spring, waiting to submit an application for accreditation could prove the financial undoing of slow-to-act providers. "You may be extremely disappointed if it turns out that your city is among the initial batch to require accreditation and you further postpone the process," says Popovich. "Let's pull a date out of the air—June 1—and say that this is the date competitive bidding officially begins in your city. You would be making a huge mistake to hold off until May 1 to send in your application for accreditation and then expect that the application will be processed, the survey scheduled and conducted, and the report and final accreditation decision processed all within 30 days in time for you to start participating in competitive bidding on June 1."

It takes an accreditor like JCAHO at least 2 months (best scenario), but usually much longer to approve a candidate for accreditation due to the processes involved—such as a thorough on-site survey of an applicant's records, policies, procedures, and facilities. Accordingly, industry consultant Mary Ellen Conway, president of Capital Healthcare Group LLC in the District of Columbia, urges HME providers everywhere—not just in start-up cities—to get in gear. "Everyone I know has been saying, ‘Don't wait!' Since all of the accreditor organizations were named on November 22, pick one and move forward," she says.

DEBUT CITIES

In 2006, JCAHO reported that the volume of applications it received from HME providers rose by 60% over the prior year. That is encouraging, especially since CMS' December 20 announcement that—whether large or small—DMEPOS suppliers in or serving the 10 chosen metropolitan statistical areas (MSAs) will this year be obliged to satisfy CMS-specified quality and performance improvement standards to bill Medicare Part B—and to participate in national competitive bidding.

The 10 MSAs to be culled from this group have not yet been announced as of press time, but Popovich has speculated (for JCAHO's planning purposes) that they will include Miami, Houston, Riverside-San Bernardino, Charlotte, Kansas City, Cincinnati, San Juan, and Pittsburgh. "Whichever the 10 cities ultimately turn out to be, we believe they will be the ones best able to give CMS a sense of the various influences that would be responsible for making a competitive bid larger or smaller in one MSA compared to another," says Popovich. "We also would expect that the first 10 will be chosen based on at least two other considerations: the presence of large numbers of Medicare beneficiaries, and a reputation for significant fraud and abuse."

MAKING PREPARATIONS

The Joint Commission—which has offered accreditation of medical equipment suppliers since 1988—began a year ago making preparations to accommodate an expected crush of accreditation applicants from those debut cities. "We've significantly increased our marketing and education efforts in each," says Popovich. "As a result, we feel we are extremely well positioned to efficiently process applications and get them through the accreditation process in a timely way."

Among the steps taken by the Joint Commission: an upgraded Web site devoted to HME accreditation; hiring an HME-experienced respiratory therapist to individually provide a point of contact for potential applicants, answer any questions, and guide them through the application process; and the addition of more surveyors to prevent a site-visit backlog.

Consultant Conway, meanwhile, has been advising her HME clients to "Pick your accreditor; get their standards; buy a good policy-and-procedure manual if you don't have one, implement CMS' performance improvement requirements; and get it done."

CRITICISMS UNDESERVED?

Last August, CMS published final quality standards. Some critics groused that the standards filled a mere 14 pages. Popovich, however, thinks the critics are wrong. "The standards are impressively robust and well thought out," she says in their defense. "In 2005, when we received the first iteration, those quality standards took up many pages—and the reason they did was because they were extremely prescriptive. In fact, the Joint Commission—along with thousands of other organizations and individuals—commented to CMS that those standards were actually too prescriptive. So, CMS carefully reevaluated what it had come up with and then spent nearly a year reworking the standards to simplify their language and, at the same time, make them more flexible for providers without sacrificing critical aspects of how quality is achieved. Even though they now are spelled out on fewer pages, I can assure that significant effort is going to be required on the part of the providers to be in compliance with the final requirements."

Popovich finds an ally for her view in Canally. "It is not just about the specifics of those 14 pages," says Canally. "It also is about what evidence the accreditor decides to look for in determining whether the applicant's programs, policies, and practices are in compliance with those 14 pages of standards. And I think this is an important point that everybody is missing."

Adds Conway: "CMS has been very clear that they are interested only in providers complying with the quality standards, not any additional ones. But CMS certainly expects organizations to survey for such things as infection control, even though CMS did not publish any infection-control standards."

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To her delight, Canally found but the scantiest need for reconciliation of The Compliance Team's existing accreditation programs and processes with CMS' specifications. "We were ecstatic to discover that every single one of our standards was utilized in the final approved version of the CMS quality standards, which meant that 99.9% of our program was perfect just the way it was, except for a few minor tweaks we had to make," she says.

Rich Smith is a contributing writer for  HME Today.